Legal and policy
Enterprise Privacy
How Lumimetrica approaches organizational and learner data for the learning organizations that use it.
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About this page
This page describes how Lumimetrica, operated by Graph25 Informatics Limited, approaches organizational data and learner data on behalf of the learning organizations that use it. It is an overview intended to support evaluation and planning.
The specific terms that govern any deployment — including data processing terms, security commitments and retention periods — are set out in the agreement between Graph25 Informatics Limited and each organization. Where this page and an agreement differ, the agreement prevails.
Roles and responsibilities
In a typical deployment:
- The learning organization decides why and how learner data is used, which data is provided to Lumimetrica, and who within the organization may access it. It is generally the controller of learner data and is responsible for the relationship with its learners.
- Graph25 Informatics Limited processes that data on the organization’s behalf and according to its documented instructions, in order to provide Lumimetrica’s learner statistics.
The precise allocation of roles is confirmed in each organization’s agreement.
Organizational data
Organizational data includes information about the organization itself and the people who use Lumimetrica on its behalf — for example, user names, work email addresses, roles, and the structure of programs, cohorts and groups. It is used to provide access, apply permissions and organize learner statistics in a way that reflects the organization.
Learner data
Learner data is the learning activity and related information that an organization chooses to provide, such as learner identifiers, participation, progression and results. Lumimetrica uses learner data to compute learner statistics for the organization that provided it: progress, growth, engagement, trajectories, cohort distributions, risk signals and outcome monitoring.
Learner data is not sold and is not used for advertising. How learner data may be used to develop or improve statistical models is defined in each organization’s agreement.
Data handling principles
Lumimetrica is designed around the following principles:
- Purpose limitation — learner data is used to provide learner statistics to the organization that supplied it.
- Data minimization — organizations are encouraged to provide only the data the statistics require.
- Separation — each organization’s data is kept logically separate from that of every other organization.
- Retention and deletion — data is kept for the period agreed with the organization and deleted or returned at the end of the engagement, as set out in the agreement.
Security
Lumimetrica is designed with protection of learner data as part of its structure, including encryption of data in transit and at rest, authenticated access, role-based permissions, activity records and operational monitoring. An overview is available in the Security section of the Lumimetrica website. Detailed security information is available to organizations on request.
Access controls
Access to Lumimetrica is granted to named users authorized by the organization. Permissions are based on roles, so that each person sees only the learners, groups and statistics that their responsibilities require. Organizations can review and change who has access.
Organizational controls
Organizations remain in control of their data. Through their administrators and their agreement with us, organizations can decide which data is provided, manage users and roles, and request export or deletion of their data.
Requests from learners
Learners who wish to exercise rights over their personal information should normally contact their learning organization, which is responsible for responding. Graph25 Informatics Limited will assist the organization as set out in its agreement.
Service providers
Graph25 Informatics Limited uses carefully selected service providers, such as infrastructure providers, to operate Lumimetrica. Information about the service providers involved in processing an organization’s data is provided as part of the agreement with that organization.
Questions
Organizations evaluating Lumimetrica can request further information about privacy, data protection and security using the contact details below.
Contact
Questions about this page can be sent to Graph25 Informatics Limited:
questions@graph25.uk+256 756 494 518
3rd Floor, Kanjokya House
Plot 90–92 Kanjokya Street
Kampala, Uganda